Dual Citizenship in the European Union: trends and analysis (2010-2020)
the update for 2020 of the GLOBALCIT Global Database on Modes of Acquisition of
Citizenship.13 If the necessary data could not be derived from this dataset, domestic citizenship
legislation of that particular state was assessed, which is referred to in a footnote. The overview
mainly focuses on dual citizenship provisions for ordinary residence-based naturalisation (A06)
and exceptions to the main rule for this mode are briefly summarised. In addition to that, other
modes of acquisition of citizenship not related to acquisition at birth (A05, A07-A27) are also
included in order to provide a comprehensive overview. If acquisition of citizenship under any
of these particular modes requires renunciation of the original citizenship, this is marked as
‘Renunciation’ or ‘Renunciation – exceptions’. A more detailed overview of applicable
exceptions will be provided in Section 3. If no renunciation is required for acquisition of
citizenship under a particular mode, this is marked as ‘No renunciation’. If a mode of
acquisition is not in place in a state, this is marked as ‘n.a.’. For loss provisions, the provisions
are marked as ‘Loss’, ‘No loss’ or ‘n.a.’. If a provision is only applicable to a particular
subcategory of citizens (e.g. only to citizens by naturalisation), this is stated in the overview
table, as the notification in the overview table could otherwise be regarded as deceptive. The
data is derived from the 2020 update for the Globalcit modes of acquisition and loss of
citizenship database.
1.2 Dual citizenship in the European Union: Analysis of national legal provisions
In 16 EU Member States (Belgium, Cyprus, Czech Republic, Denmark, Finland, France,
Greece, Hungary, Italy, Luxembourg, Malta, Poland, Portugal, Romania, Sweden and the
United Kingdom), there are no restrictions in place on dual citizenship for foreign nationals
who acquire the citizenship of the country or citizens who acquire the citizenship of a foreign
country. As these Member States constitute a majority, this again underlines that toleration of
dual citizenship is steadfastly becoming the norm within the European Union.
In seven EU Member States (Austria, Estonia, Germany, Latvia, Lithuania, the
Netherlands and Spain), restrictions on dual citizenship are in place for both persons who
acquire the citizenship of the country as well as citizens of the country who acquire the
citizenship of a foreign country. In five other EU Member States, dual citizenship is restricted
asymmetrically. In Bulgaria, Croatia and Slovenia, dual citizenship is restricted for those who
acquire citizenship, but not for citizens who acquire a foreign citizenship. In Ireland and
Slovakia, restrictions on dual citizenship are in place for citizens who acquire a foreign
citizenship, but not for those who acquire citizenship.
1.2.1
Requirement to renounce the original citizenship upon the acquisition of citizenship
(Globalcit modes of acquisition A05-A27)
In ten EU Member States (Austria, Bulgaria, Croatia, Estonia, Germany, Latvia, Lithuania, the
Netherlands, Slovenia and Spain), acquiring citizenship through residence-based naturalisation
(A06) requires that the original citizenship of the applicant is either expressly renounced or that
the original citizenship was lost in an alternative way (e.g. through automatic loss).
It is important to note that the renunciation requirement is in many EU Member States
not consistently applied to all modes of acquisition of citizenship. Seven restrictive Member
13
Global Database on Modes of Acquisition of Citizenship, Globalcit, San Domenico di Fiesole: European
University Institute, via <http://globalcit.eu/acquisition-citizenship/>, last accessed on 20 June 2020.
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RSCAS/GLOBALCIT-Comp. 2020/4 - © 2020 Author